TMI Blog2023 (12) TMI 278X X X X Extracts X X X X X X X X Extracts X X X X ..... impugned rectification process for the purpose of disallowing the assessee s foregoing prior period expenses - HELD THAT: He fails to dispute the clinching fact emerging from the case records that the AO had very well issued sec. 142(1) notice seeking to disallow the same on 26.02.2016 i.e., prior to sec. 143(3) assessment which stood duly explained by the assessee on 08.03.2016. These relevant ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... CIT(A)-3/6/2018-19, dated 29.04.2019, involving proceedings u/s. 154 r.w.s. 143(3) of the Income Tax Act, 1961 (in short the Act ). Heard both the parties. Case file perused. 2. The Revenue raises the following substantive grounds in the instant appeal : 1. On the facts and circumstances of the case, the Ld. CIT(Appeals) has erred in holding that the disallowance amounting to Rs. 16,30 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... le Tribunal. 3. It next emerges with the able assistance coming from both the parties that there is hardly much a need for us to delve deeper in the relevant factual matrix once it has come on record that we are dealing with sec. 154 rectification proceedings. We further note that the learned Assessing Officer had invoked his impugned jurisdiction to disallow prior period expenses of Rs. 16,3 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... R 50 (SC) that purpose of sec. 154 rectification is only to deal with apparent mistakes on record than those involving detailed roving enquiries and confirm the CIT(A)'s action reversing the Assessing Officer s impugned action to this effect. Ordered accordingly. 5. This Revenue s appeal is dismissed in above terms. Order pronounced in the open Court on 30.11.2023. - - TaxTMI - TMIT ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
